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NOT Flying Under The Radar – The Many FCPA Enforcement Actions Against Companies In The Aviation Industry

When compiling a list of the industries that have the highest Foreign Corrupt Practices Act risk, the aviation industry is probably not going to be near the top of many lists.

However, it should be because as highlighted in this post there have been approximately 20 corporate FCPA enforcement actions against companies in the industry (broadly defined) in FCPA enforcement history resulting in approximately $860 million in settlement amounts. Last week’s enforcement action against Airbus (see here [1] for the prior post) was merely the most recent example.

In fact, the aviation industry was front and center in “The Story of the Foreign Corrupt Practices Act [2]” as Lockheed’s payments to Japanese Prime Minister Tanaka, Prince Berhard (the Inspector General of the Dutch Armed Forces and the husband of Queen Juliana of the Netherlands) and Italian political parties was arguably the most high profile example of foreign corporate payments Congress learned about in the mid-1970’s which motivated it to enact the FCPA.

The remainder of this post highlights FCPA enforcement actions against companies in the aviation industry broadly defined.

Airbus (2020)

Panasonic (2018)

United Technologies (2018)

Embraer (2016)

LAN / LATAM Airlines (2016)

Dallas Airmotive (2014)

NORDAM Group (2012)

BizJet International / Lufthansa (2012)

United Industrial Corp. (2009)

InVision Technologies (2004)

UNC/Lear Services (2000)

International Material Solutions (1999)

Control Systems Specialists (1998)

Lockheed (1994)

General Electric (1992)

Venturian Corp. / NAPCO International / Dornier (1989)

W.S. Kirkpatrick Inc. (1985)

Page Airlines (1978)